Fountain Valley Chateau Blanc Homeowner’s Association v. Department of Veteran Affairs

Brief Fact Summary.

Defendant purchased a residence from Plaintiff that contained restrictive covenants, restrictions, and conditions, one which required the residence to remain clean and attractive. The agreements also allowed Defendant do furnish and decorate his residence as he saw fit. Plaintiff brought suit on the grounds that Defendant’s residence was a violation of the agreement, which resulted in a settlement. Defendant brought a cross-complaint against Plaintiff., and the trial court granted Plaintiff a new trial. Defendant appealed.

Synopsis of Rule of Law.

A homeowner’s association cannot order a homeowner where he or she may place nonhazardous objects or the amount of non-hazardous objects of homeowner’ may have in his or her residence, even if the agreement contains a covenant requiring the interior for the house to be properly maintained.

Facts.

Defendant, Robert Cunningham, bought a residence that was subject to protective covenants, conditions, and restrictions by the Fountain Valley Chateau Blanc Homeowner’s Association, Plaintiff. The protective covenants, conditions, and restrictions stated that the home owners had an obligation to maintain the interior of the residence clean and attractive, as well as giving the owners a right to decorate the interior of the house as they saw fit. Defendant purchased the residence with the assistance of the United States Department of Veteran Affairs, who had title to the land under a land-sale installment agreement. Thereafter, Plaintiff disputed the paper, appliances, and books that Defendant had in his residence, demanding Defendant to remove the property or be subject to litigation. Defendant moved some of the items, not all. Plaintiff filed suit against Defendant and the United States Department of Veteran Affairs. Fire and housing code inspectors went to the property and did not find any hazardous conditions on Defendant’s property. Yet, Plaintiff still sent Defendant a letter demanding him to clean the remaining paper, boxes, and books from the floor and bed and remove Defendant’s old clothes. Defendant filed a cross complaint against Plaintiff alleging Plaintiff committed trespass, negligence, and a breach of contract. Plaintiff’s complaint was subsequently settled. Under Defendant’s cross complaint, the jury found that Plaintiff acted unreasonably. However, the judge granted Plaintiff a new trial on the grounds that Plaintiff acted reasonably.

Issue.

Whether a homeowner’s association can order a homeowner where he or she may place nonhazardous objects or the amount of non-hazardous objects of homeowner’ may have in his or her residence.

Held.

No, a homeowner’s association cannot order a homeowner where he or she may place nonhazardous objects or the amount of non-hazardous objects of homeowner’ may have in his or her residence, even if the agreement contains a covenant requiring the interior for the house to be properly maintained.

Discussion.

A homeowner’s association has a legitimate interest in preventing the reduction of property values and preventing hazardous materials onto the property. However, this interest cannot apply to the location of books, papers, or clothing inside a homeowner’s residence. A homeowner’s association cannot micromanage the interior of the homeowner’s home. The convent in this case solely requires cleanliness. The fire inspector and the housing code inspector did not find any violations to the property. The aesthetic of the interior of the home is not a valid objection to Defendant’s use of the home. Therefore, a reasonably jury could find that the Plaintiff acted unreasonably, and the trial court’s grant of a new trial is reversed. The case must proceed to determine damages.